Foreign Companies and Nationals Targeted by New US Department of Justice Guidelines

On June 9, 2025, the U.S. Department of Justice (“DOJ”) lifted the temporary suspension of Foreign Corrupt Practices Act (“FCPA”) prosecutions that had been in place since February and issued new enforcement guidance aimed at reshaping the direction of future cases.

In their Finascope analysis, Cohen & Gresser partners Muriel Goldberg-Darmon and Christian R. Everdell note that the new directives signal heightened risks for non-U.S. companies and individuals, particularly those that compete directly with U.S. businesses in economic sectors that are strategically important or impact U.S. national security interests.